DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(1)(1), BANGALORE vs. M/S. CANADIAN INTERNATIONAL SCHOOL PRIVATE LIMITED, BANGALORE

In the result appeal filed by revenue stands dismissed

Bench: Shri. B.R Baskaran & Smt. Beena Pillaiita 2535/Bang/2019 Assessment Year : 2016-17

section 68 of the Act in the hands of assessee to an extent of Rs.1,68,70,000/-. 2.3 Aggrieved by the addition made by the Ld.AO, assessee filed appeal before the Ld.CIT (A). 3. The Ld.CIT(A) after considering the submissions of assessee observed and held as under: “6 I have considered the grounds of appeal, statement

MUDHOL PATTINA SAHAKARI SANGH NIYAMITA,MUDHOL vs. INCOME TAX OFFICER WARD-1, BAGALKOT

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri George George Kassessment Year : 2017-18 M/S. Mudhol Pattina Sahakari Sangh Niyamita, Vs. Acit, Gokul Complex, Gandhi Circle, Mudhol, Circle – 1, Mudhol Dist, Bagalkot – 587 313, Hassan. Karnataka. Pan : Aaeam 7882 P Appellant Respondent Assessee By : Shri. Veeranna M. Murgod, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 18.12.2023 Date Of Pronouncement : 19.12.2023

202/-. The assessment was selected for scrutiny and notice under section 143(2) of the Act was issued on 07.09.2018. Assessment was completed under section 143(3) of the Act vide order dated 05.12.2019. In the assessment completed, the claim of deduction under section 80P of the Act was denied. The AO also made an addition

PUKHRAJ,SHIVAMOGGA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, SHIVAMOGGA

In the result, appeal of the assessee is allowed

Bench: Shri. George George K & Ms. Padmavathy Sassessment Year : 2017-18 Shri. Pukhraj, Vs. Acit, Prop: Kissan Trading Co., Circle – 1, Bhati Complex, Shivamogga. 1St Cross Garden Area, Shivamogga – 577 202. Pan : Afjpp 7695 A Appellant Respondent Assessee By : Smt. Suman Lunkar, Ca Revenue By : Smt. Priyadarshini Baseganni, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 13.07.2022 Date Of Pronouncement : 19.07.2022 O R D E R Per Padmavathy S

202. PAN : AFJPP 7695 A APPELLANT RESPONDENT Assessee by : Smt. Suman Lunkar, CA Revenue by : Smt. Priyadarshini Baseganni, Addl. CIT(DR)(ITAT), Bengaluru. Date of hearing : 13.07.2022 Date of Pronouncement : 19.07.2022 O R D E R Per Padmavathy S, Accountant Member This appeal is against the order of the National Faceless Centre (NFAC) passed under section

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

202 Government in the subsequent year and, therefore, depreciation could not be deducted on the capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

202 Government in the subsequent year and, therefore, depreciation could not be deducted on the capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount

SMT. LIZY GEORGE,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(1), BANGALORE

In the result, the appeal of the assessee is partly allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2005-06

68, 70 (30/04/2011), 352, 353) and on the record of the revenue, has not been scrutinized and the AO was not justified in making a passing mention that a substantial portion of the confirmations were not satisfactory, without having verified the same. k. In view of the above, the appellant submits that she has made every effort to comply with

HANUMANTHAPPA PATHRERA LAXMANA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-(1) & TPS, SHIMOGGA

In the result, the assessee’s appeal is partly allowed whereas the Revenue’s appeal is dismissed

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2020-21

202. PAN – ADCPL 4413 F APPELLANT RESPONDENT Assessee by : Shri Atul K Alur, Advocate Revenue by : Shri Shivanand H Kalakeri, JCIT (DR) Date of hearing : 13.08.2025 Date of Pronouncement : 09.10.2025 O R D E R ITA No.247 & 1066/Bang/2025 Page 2 of 8 PER WASEEM AHMED, ACCOUNTANT MEMBER: These cross appeals, one by the assessee and the other by the Revenue

INCOME TAX OFFICER, WARD-1 & TPS, SHIVAMOGGA vs. HANUMANTHAPPA PATHRERA LAXMANA, SHIVAMOGGA

In the result, the assessee’s appeal is partly allowed whereas the Revenue’s appeal is dismissed

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2020-21

202. PAN – ADCPL 4413 F APPELLANT RESPONDENT Assessee by : Shri Atul K Alur, Advocate Revenue by : Shri Shivanand H Kalakeri, JCIT (DR) Date of hearing : 13.08.2025 Date of Pronouncement : 09.10.2025 O R D E R ITA No.247 & 1066/Bang/2025 Page 2 of 8 PER WASEEM AHMED, ACCOUNTANT MEMBER: These cross appeals, one by the assessee and the other by the Revenue

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

202 ITR 932 Bombay HC)\n• Jagannath Hanumanbux v. ITO (31 ITR 603)\n• Lalji Haridas v. ITO (1961 43 ITR 387 SC)\n17.5 These cases establish the principle that the same income cannot\nbe assessed substantively in multiple hands. However, these rulings\nprimarily deal with situations where the AO assessed multiple legal heirs\nseparately on a substantive basis, resulting